The CPUC should not adjust rates at this time but wait until it completes its investigation

Immediate reduction risks creating rate shock - if and when Units 2 and 3 are returned to service. (This concern only applies if the units can return to service, which is unlikely).

Maintaining rates allows SCE to work toward restart.

SCE says $345 million (of the authorized $739 million SONGS annual revenue requirement) be made subject to refund.

SCE requests that $115 million be included in the rates for 2012 for the SGRP -- and SCE has removed $115.0 million from the SONGS 2&3 authorized revenue requirement that will be set subject to refund in this proceeding because this amount is already subject to refund due to the BRRBA (Base Revenue Requirement Balancing Account). Thus, the expectation is that this will be automatically refunded (but may only partially be refunded).

SCE similarly asserts that $103 million should be removed from consideration because it is already handled by ERRA, Energy Resource Recovery Account (for fuel costs).

SCE asserts that $50.1 million for seismic study projects be left in the rate base.

SCE says decommissioning trust payments ($23 million) should not be under consideration.

SCE says marine mitigation activities required by California Coastal Commission. 1974 California Coastal Zone Conservation Commission permit (No. 6-81-330- A, formerly 183-73) required SCE to study the impacts of the operation of SONGS 2&3 on the marine environment offshore from San Onofre, and to mitigate any adverse impacts. As a result of these impact studies, in 1991, the Coastal Commission added new conditions requiring SCE to mitigate the adverse impacts of the power plant on the marine environment by: